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Data Controller
The swankysoftware.net website is operated by Muhammed Mustafa Geldi (Türkiye), operating under the name Swanky Software (referred to in this policy as “Swanky Software”).
With regard to the personal data processed in connection with the website, the data controller is Swanky Software. Questions and requests concerning personal data may be sent to [email protected].
Scope
This policy covers only the data processed when the website is visited and when you contact us by email through the website. The data processed in Swanky Software applications is described in each application’s own privacy policy; you can find these policies on the Policies and terms page.
The website can be visited from anywhere in the world, and this policy applies in the same way to all visitors regardless of the country in which they are located. As the data controller is established in Türkiye, all processing activities are subject to the KVKK; processing relating to visitors in the European Economic Area is additionally subject to the GDPR. Where the laws of your country grant you rights in addition to those set out in this policy, those rights remain unaffected.
How the Website Works
The website consists only of informational pages. The website has no registration, sign-in, forms or payments; it does not use cookies, analytics, advertising or tracking tools. Fonts and images are loaded from the website’s own server; no request is sent to a third-party service while you view the pages.
The only exception is the email verification and password reset pages opened by links emailed to Wordify users. These pages send the one-time token in the link and, for a password reset, your new password directly from your browser to Supabase, Wordify’s authentication service; this information is not sent to the website’s server and is not stored in your browser. Your data in these operations are processed under the Wordify Privacy Policy.
Personal Data Processed
- Server logs: When you visit the website, the IP address sent by your browser, the date and time of the visit, the page requested, the response status, the referring page, and browser and operating system information are automatically logged by the web server.
- Network infrastructure records: Requests to the website are routed through the Cloudflare network. In the process, the IP address and request information are processed by Cloudflare for security and availability purposes.
- Email correspondence: When you send us an email using the contact links on the website, your email address, your name (if you provide it) and the content of your message are processed. These links only open your own email application; the message is transmitted when you send it.
Purposes and Legal Bases of Processing
Personal data are not processed for advertising, profiling or marketing purposes and are not sold.
- Providing and securing the website: Delivering the pages, detecting and preventing attacks and misuse, and fixing errors. Legal basis: legitimate interest of the data controller (Art. 5(2)(f) KVKK; Art. 6(1)(f) GDPR) and the legal obligation relating to data security (Art. 12 KVKK).
- Responding to enquiries: Responding to questions, support requests and data protection requests sent by email. Legal basis: necessity for handling your request and legitimate interest of the data controller (Art. 5(2)(c) and (f) KVKK; Art. 6(1)(b) and (f) GDPR); for requests concerning personal data, legal obligation (Art. 5(2)(ç) KVKK; Art. 6(1)(c) GDPR).
- Legal obligations and disputes: Complying with lawful requests from competent authorities and protecting rights in possible disputes. Legal basis: legal obligation and the establishment, exercise or defence of a right (Art. 5(2)(ç) and (e) KVKK; Art. 6(1)(c) and (f) GDPR).
Cookies and Browser Storage
The website does not use its own cookies. In situations such as unusual traffic or suspected attacks, Cloudflare may set strictly necessary cookies used solely for security purposes to verify the visitor. These cookies are not used for advertising or tracking.
If you choose the light or dark theme with the button at the top of the page, this preference is stored only in your browser’s local storage (localStorage) as the value “light” or “dark”. This information stays on your device; it is not sent to our server or to third parties and is not used to identify or track you. Because the preference is stored solely at your request and to provide the appearance you have chosen, no separate consent is required. You can delete it at any time by clearing your browser’s site data; if you do not use the theme button, no information is stored in your browser.
Disclosure of Personal Data
Data are disclosed only to the recipients listed below and only for the stated purposes.
Service providers and other recipients
- Server infrastructure: The website is hosted on a server located in Germany and managed by Swanky Software.
- Cloudflare: The network infrastructure used to provide fast and secure access to the website. For details, see the Cloudflare Privacy Policy.
- Hostinger: Emails sent to [email protected] and other @swankysoftware.net addresses are hosted on the infrastructure of the email service provider Hostinger. For details, see the Hostinger Privacy Policy.
- Competent authorities: Data are disclosed to public authorities and courts empowered by law only where there is a legal obligation to do so and only to the extent required by that obligation.
Countries where data are processed
Regardless of the country in which the visitor is located, personal data are processed on the server in Germany and on the infrastructure of Cloudflare and Hostinger in various countries, including the United States. Your data may therefore be processed outside your country.
With regard to transfers from Türkiye, these transfers are based on the appropriate safeguards provided for in Article 9 of the KVKK; with regard to transfers from the European Economic Area, they are based on the safeguards provided for in Chapter V of the GDPR, in particular standard contractual clauses and, where applicable, the EU-U.S. Data Privacy Framework.
External Links
The website contains links to third-party sites such as Google Play. When you follow these links, the privacy policy of the relevant site applies. Swanky Software is not responsible for the data processing activities of third-party sites.
Data Security
In accordance with Article 12 of the KVKK and Article 32 of the GDPR, Swanky Software takes appropriate technical and organisational measures to ensure the security of personal data. All connections to the website are encrypted with HTTPS, and the website is served with security rules that allow the browser to load only the website’s own resources.
No system can guarantee absolute security. If personal data are unlawfully obtained by others, the competent data protection authorities and the affected individuals will be notified within the time limits and in the manner prescribed by law.
Retention Periods
- Server logs: Retained for the short period required for security and error detection purposes and deleted at the end of that period.
- Cloudflare records: Retained by Cloudflare in accordance with its own retention rules.
- Email correspondence: Retained for as long as necessary to resolve the request and to provide evidence in possible disputes.
Your Rights
Regardless of the country in which you are located, you have the following rights regarding your personal data (Art. 11 KVKK; Arts. 15–22 GDPR):
- Information: To learn whether your personal data are processed and, if so, to request information about it, and to learn the purpose of the processing and whether the data are used in accordance with that purpose.
- Recipients: To know the third parties to whom your personal data are transferred, whether domestically or abroad.
- Rectification: To request the rectification of incomplete or inaccurate personal data.
- Erasure: To request the erasure or destruction of personal data under the conditions provided for by law.
- Restriction: To request, in certain cases, that the processing of your personal data be restricted.
- Data portability: To request the personal data you have provided in a structured, commonly used format.
- Notification: To request that rectification, erasure or destruction be notified to the third parties to whom the data have been transferred.
- Objection: To object to processing based on legitimate interest and to a result to your detriment arising from analysis carried out exclusively by automated systems.
- Compensation: To claim compensation for damage suffered as a result of the unlawful processing of your personal data.
How to Submit a Request
You may send requests concerning your rights to [email protected]. For requests concerning server logs, you may need to state the date of your visit and the IP address you used so that the records can be found. Additional information may be requested if your identity cannot be verified.
Requests are handled as quickly as their nature allows and free of charge within thirty days at the latest.
If you are not satisfied with the outcome of your request, you may lodge a complaint with the competent data protection authority. Visitors in Türkiye may apply to the Turkish Personal Data Protection Board within thirty days of learning of the response and in any event within sixty days of the date of the request; see the KVKK right to apply page for details. Visitors in the European Economic Area may apply to the data protection authority of the country in which they reside or work, and visitors in other countries may apply to the competent authority in their country.
Changes to This Policy
This policy may be updated in line with changes to the website, the services used or the applicable law. The current version is published on this page, and the date of the last update is shown at the top of the page.
