Privacy Policy

Effective date: 10 October 2026

1. Who we are

Undoly is published by Emre Keskin, an individual developer based in Türkiye ("we", "us"). We are the data controller (in Türkiye, the "veri sorumlusu" under KVKK) for the limited personal data described in this policy. Contact: plustekno1@gmail.com. You can use this address for every request in this policy, including requests from the EU, UK, US, Brazil and other regions. We have not appointed an EU or UK representative because we do not systematically process personal data of people in those regions beyond the purchase data described below; you can still contact us directly.

2. Data that stays on your device (we never receive it)

• Gallery Protection: if you turn it on, copies of the photos and videos you choose (last 30 days, 6 months, 1 year or your whole library) are kept only in Undoly's private storage on your device so that deleted items can be restored. You can pause copying, change the period, or delete all copies in Settings.
• Vault: photos and videos you move to the Vault are stored only on your device. Your 4-digit PIN is stored as a salted hash in the device Keychain. Face ID is handled by iOS; we never see biometric data.
• Intruder photo (optional, Pro): after wrong PIN attempts a front-camera photo is saved only inside the Vault on your device.
• Contacts: if you turn on contact protection or create a contacts backup, a copy of your address book is kept on your device (or in a file you choose to save or share).
• Clean Up, Enhance, Compress, sensitive document scan and smart search: all image analysis, including the AI colorize and upscale models, runs on your device. Images are never uploaded.
• Settings and usage counters (for example remaining free allowances) are stored on your device and in your device Keychain.

Because this data never reaches us, we cannot access, read, recover or delete it for you. Deleting Undoly, or using Settings > Delete All Data, removes it from your device. Items stored in the iOS Keychain may remain until you reset the device.

3. Data that leaves your device

• Apple (App Store and payments). Purchases, free trials, renewals, cancellations and refunds are processed by Apple under Apple's own privacy policy. We never receive your name, email address, payment card or Apple Account details. Apple gives us aggregated, anonymous sales and usage statistics, and crash reports only if you have chosen to share analytics with app developers in iOS Settings.
• RevenueCat (subscription analytics). To understand trials, conversions, renewals and cancellations we use RevenueCat, Inc. (USA) as a service provider/processor. When you open the app or make a purchase, RevenueCat receives a random app user identifier generated by RevenueCat (not linked to your name or Apple Account), your purchase and subscription transactions (product, price, currency, dates, trial and renewal status, App Store transaction identifiers), the App Store country, app version, operating system version, device model and the IP address of the request. RevenueCat processes this data only on our behalf. See revenuecat.com/privacy.
• Apple servers for downloads. The colorize AI model is downloaded once from Apple's servers when you first use it. If you choose to download photos stored in iCloud for Gallery Protection, iOS downloads them from your own iCloud account.
• Your own iCloud (only if this option is available in your version and you turn it on): an encrypted Vault backup is stored in your own iCloud Drive. The encryption key stays in your iCloud Keychain; we cannot read the backup.
• Support emails. If you email us, we receive your email address and whatever you choose to send, and use it only to answer you.

We do not use advertising SDKs, advertising identifiers (IDFA), third-party analytics or tracking technologies, and we do not ask for App Tracking Transparency permission.

4. Why we process data and our legal bases

• Providing Undoly and Undoly Pro (purchase validation, restoring purchases, managing your subscription): performance of a contract (GDPR/UK GDPR Art. 6(1)(b); KVKK Art. 5(2)(c); LGPD Art. 7(V)).
• Subscription analytics, fraud prevention and improving the app using pseudonymous purchase data: our legitimate interests in running a sustainable app (GDPR Art. 6(1)(f); KVKK Art. 5(2)(f); LGPD Art. 7(IX)). You can object at any time (see section 7).
• Accounting and tax obligations on aggregated sales: legal obligation (GDPR Art. 6(1)(c); KVKK Art. 5(2)(ç)).
• Answering your messages: your request and our legitimate interest.
• Device permissions (Photos, Camera, Microphone, Contacts, Face ID, Notifications) are requested only when you use the related feature, and only to make that feature work on your device. You can withdraw them anytime in iOS Settings.

We do not make decisions based solely on automated processing that produce legal or similarly significant effects, and we do not profile you.

5. Sharing, selling and international transfers

We do not sell personal data and we do not "share" it for cross-context behavioral advertising (as defined in the California CCPA/CPRA). We disclose the limited data in section 3 only to our service providers Apple and RevenueCat, which process it under contracts that restrict its use. We may disclose information if required by law or to protect our rights.

RevenueCat and Apple may process data in the United States and other countries. Where data protection law requires it, transfers are protected by appropriate safeguards such as the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum, the EU-US Data Privacy Framework where applicable, and, for transfers from Türkiye, the standard contracts and procedures under KVKK Article 9.

6. How long we keep data

On-device data stays until you delete it or delete the app. Pseudonymous purchase records at RevenueCat are kept while your subscription history is needed for analytics and validation, and are deleted on request (section 7) or when we close our RevenueCat project. Support emails are kept for up to 2 years. Apple keeps transaction data under its own policy.

7. Your rights

Depending on where you live, you have some or all of these rights: to know and access the personal data we hold about you, to correct it, to delete it, to receive it in a portable format, to restrict or object to processing (including processing based on legitimate interests), to withdraw consent, and not to be subject to solely automated decisions. You will not be treated differently for exercising your rights.

• EU/EEA, UK and Switzerland (GDPR, UK GDPR, FADP): all rights above, plus the right to complain to your data protection authority (for example your national DPA, the UK ICO or the Swiss FDPIC).
• Türkiye (KVKK Art. 11): to learn whether your data is processed and request information, to learn the purpose and whether it is used accordingly, to know third parties in Türkiye or abroad to whom it is transferred, to request correction or deletion and notification of these to third parties, to object to a result against you arising from exclusively automated analysis, and to claim compensation for damage from unlawful processing. You may also complain to the Personal Data Protection Board (KVKK Kurulu).
• United States (California CCPA/CPRA and the privacy laws of Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Iowa, Delaware, New Hampshire, New Jersey, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Nebraska, Rhode Island and other states): right to know/access, delete, correct, portability, and to opt out of sale, sharing, targeted advertising and profiling. We do none of these, so there is nothing to opt out of; we also honor Global Privacy Control signals. In the last 12 months we collected the categories "identifiers" (random app user ID), "commercial information" (purchase history) and "internet or network activity" (request IP address), from your device, for the business purposes in section 4, and disclosed them only to service providers. We do not collect sensitive personal information for inferring characteristics. You may use an authorized agent; we may ask you to verify the request. If we deny a request you can appeal by replying to our answer.
• Brazil (LGPD): confirmation of processing, access, correction, anonymization, blocking or deletion, portability, information about sharing, and revocation of consent; you may complain to the ANPD.
• Canada (PIPEDA, Quebec Law 25), Australia (Privacy Act and APPs), New Zealand, Japan (APPI), South Korea (PIPA), India (DPDP Act 2023), Singapore, Malaysia, Thailand, the Philippines, Indonesia, Vietnam, South Africa (POPIA), Saudi Arabia (PDPL), the UAE, Israel and other countries: you have the access, correction, deletion and complaint rights provided by your local law, which you can exercise as described here.

How to exercise your rights: email plustekno1@gmail.com. Because we do not know who you are, please include your RevenueCat/app user ID if you can (visible to us only through purchase records) or the App Store order date and product, so we can find the matching pseudonymous record. We answer within 30 days (KVKK: within 30 days; GDPR: within one month, extendable by two months for complex requests; US: within 45 days). Data that exists only on your device can be deleted by you at any time in Settings > Delete All Data or by deleting the app.

8. Children

Undoly is a general-audience utility and is not directed to children under 13 (or the higher age set by your country, such as 16 in some EU countries). We do not knowingly collect personal data from children. Purchases by minors are handled by Apple's Family Sharing and Ask to Buy controls. If you believe a child has provided us data, contact us and we will delete it.

9. Security

On-device data is protected by iOS sandboxing and data protection, the Vault PIN (salted hash in the Keychain) and optional Face ID. Data sent to Apple and RevenueCat is encrypted in transit (HTTPS/TLS). No method is perfectly secure; if a breach affecting your personal data occurs, we will notify you and the authorities as required by law.

10. Changes

We may update this policy when the app or the law changes. We will post the new version here with a new effective date and, for material changes, tell you in the app or in the App Store release notes.

11. Contact

Emre Keskin, Undoly · plustekno1@gmail.com