Privacy Policy

This Privacy Policy ("Policy") applies to the Morse Code Fun and Galericilik Simülatörü apps ("Apps") published by Varesma ("Varesma", "we", "us") on the Apple App Store and Google Play Store under the developer name Varesma, and to the varesma.com website ("Site").

It explains what data we process, for which purposes and on what legal bases, who we share it with, how long we keep it and how you can exercise your rights. It has been prepared taking into account Türkiye's Personal Data Protection Law No. 6698 ("KVKK"), the EU/UK General Data Protection Regulation ("GDPR") for users in the European Economic Area (EEA), the United Kingdom and Switzerland, and the CCPA/CPRA for users in California, USA.

Please read this Policy carefully before using the Apps. If you do not agree with any part of it, we recommend that you do not use the Apps.

Our Apps do not require you to create an account, sign in or enter personal information. The Apps do not collect your name, email address, phone number, contacts, photos or videos, precise (GPS) location, health or financial information.

To run the Apps, show ads and fix bugs, the following data may be processed automatically from your device and through the third-party services we use. This data is not linked to your name or contact details; it is kept under pseudonymous identifiers.

Data inventory per app

Data you provide to us directly

When you contact us via the contact form or email, your name, email address, the content of your message and any device/app details you choose to include are processed solely to respond to your request.

We process data only for the following purposes and on the stated legal bases:

We do not use your data to make solely automated decisions that produce legal or similarly significant effects concerning you. If we need to use your data for a new purpose not described here, we will inform you in advance and obtain your consent where required.

Our Apps only request permissions that are directly required for the feature they provide. Where a runtime permission is needed, the operating system's standard permission dialog is shown; if you decline, the App continues to work except for the related feature. You can revoke permissions at any time in your device Settings.

Our Apps do not access your contacts, SMS or call logs, photo library, precise location or the list of other apps installed on your device.

Our Apps use software development kits (SDKs) from the following service providers. These providers process data in accordance with their own privacy policies and the data processing terms agreed with us:

The Apps may contain links or ads that lead to third-party websites. We are not responsible for the privacy practices of those sites or advertisers; we recommend reviewing their policies before visiting.

To keep developing our free apps, we show ads through Google AdMob. You can manage your ad preferences as follows:

• iOS – App Tracking Transparency (ATT): On iOS 14.5 and later, your permission is requested via the system dialog before your advertising identifier (IDFA) is accessed. If you decline, the IDFA is not accessed and non-personalised ads are shown. You can change this in Settings > Privacy & Security > Tracking.
• Android – Advertising ID: You can reset or delete your advertising ID in Settings > Google > Ads (or Settings > Privacy > Ads).
• EEA, UK and Switzerland: Users in these regions are shown a consent screen through Google's IAB TCF-compliant consent management solution (User Messaging Platform). Personalised ads are shown only with your consent, and you can change your choice at any time from the in-app privacy options.
• Non-personalised ads may still use limited data (e.g. IP address, device information) for frequency capping, aggregated reporting and fraud prevention.

Learn how Google uses data for advertising on the Google Partner Sites page and manage your preferences in My Ad Center.

Some of our apps (Galericilik Simülatörü) offer optional in-app purchases. Purchases are handled entirely through the Apple App Store or Google Play billing system. Your payment details are processed only by Apple or Google; we only receive transaction information confirming the purchase (product ID, transaction ID, date).

Refund requests are subject to the relevant store's policies: reportaproblem.apple.com for iOS and your Google Play order history for Android.

We do not sell, rent or trade your personal data for money. Your data may only be shared in the following cases:

• Service providers: the advertising, analytics, crash reporting and payment providers listed under "Third-Party Services";
• App stores: Apple Inc. and Google LLC in connection with app distribution and purchases;
• Legal requirements: in response to lawful requests from competent authorities, court orders or legal obligations;
• Protection of rights: to the extent necessary to prevent fraud, ensure security or defend legal claims;
• Business transfers: in the event of a merger, acquisition or asset transfer, with the protections of this Policy maintained.

International transfers: Our service providers' servers may be located outside your country (primarily in the USA and the EU), so your data may be transferred abroad. Transfers from the EEA rely on GDPR-compliant mechanisms such as the European Commission's Standard Contractual Clauses or adequacy decisions (e.g. the EU-US Data Privacy Framework); transfers from Türkiye rely on the appropriate safeguards set out in Article 9 of the KVKK (e.g. standard contracts) and, where required, your explicit consent.

We keep data only for as long as necessary for the purpose for which it is processed:

When the retention period ends, data is deleted, destroyed or anonymised. See the Data Deletion page for your deletion options.

We apply reasonable technical and organisational measures to protect your data: data transmitted between the Apps and our service providers is encrypted with TLS/HTTPS, access to service accounts is restricted to authorised persons and protected with multi-factor authentication, and only necessary data is collected (data minimisation).

However, no method of transmission over the internet or electronic storage is 100% secure. In the event of a data breach, we will notify affected individuals and the competent authorities as required by applicable law.

Our Apps are intended for a general audience and are not specifically designed for children under 13; they are not part of the Google Play "Families" programme or the App Store "Kids" category. We do not knowingly collect personal data from children under 13 (or under the age of digital consent in your country, up to 16 in the EU).

If you believe a child has provided us with personal data, please contact us at info@varesma.com and we will delete it without delay.

Rights under the GDPR (EEA, UK, Switzerland)

You have the right to access, rectify and erase your data (the "right to be forgotten"), to restrict processing, to data portability and to object to processing based on legitimate interests. Where processing is based on consent, you may withdraw it at any time (without affecting the lawfulness of processing before withdrawal). You also have the right to lodge a complaint with the data protection supervisory authority in your country.

Rights under the CCPA/CPRA (California)

You have the right to know and access the personal information we collect about you, to request its deletion and correction, to opt out of the "sale" or "sharing" of your personal information and not to be discriminated against for exercising these rights. We do not sell personal information for money; however, personalised advertising may be considered "sharing" under the CPRA. You can opt out using your device's ad tracking settings or by contacting us.

Rights under the KVKK (Türkiye)

Under Article 11 of the KVKK you have the right to learn whether your data is processed, request information about it, learn the purpose of processing, know the third parties to whom it is transferred, request rectification, erasure or destruction, request notification of these operations to third parties, object to outcomes resulting solely from automated analysis and claim compensation for damages arising from unlawful processing.

How to exercise your rights

Send your request via the contact form by choosing "Privacy / Data Deletion Request" or email us at info@varesma.com. Including the app name and platform (iOS/Android) speeds up the process. We may ask for additional information to verify your identity.

Requests are handled free of charge within 30 days at the latest. If you are not satisfied with our response, you may lodge a complaint with your local supervisory authority (or, in Türkiye, the Personal Data Protection Board).

The varesma.com website does not use cookies and contains no analytics, advertising or social media tracking tools. All files, including fonts, are served from our own server and no requests are sent to third-party servers during your visit.

To keep the Site running securely, our hosting provider's servers may keep standard access logs such as IP address, browser type, page visited and timestamp. These logs are used only for security, troubleshooting and the hosting provider's legal obligations, and are deleted after the period required by law.

Contact form: When you submit the form, the information you enter is sent to us by email; it is not stored in a separate database on the Site. To prevent spam, a short-lived rate-limit record based on an irreversible hash of your IP address is kept and deleted within one hour at the latest.

If we start using cookies or similar technologies in the future, we will update this section and ask for your consent where required.

In accordance with Article 10 of the Personal Data Protection Law No. 6698 and the related Communiqué on the obligation to inform:

• Data controller: Varesma – info@varesma.com
• Categories of data: transaction security (device and advertising identifiers, IP address, diagnostic logs), marketing (ad interactions, usage data), customer transactions (purchase verification data, support requests) and, only when you contact us, identity and contact data (name, email).
• Purposes: providing and improving the Apps, fixing bugs, running advertising and analytics, ensuring information security, responding to requests and complaints and complying with legal obligations.
• Method and legal basis: data is collected by automated or partly automated means through the Apps, integrated SDKs, the website and email, and processed on the legal bases of KVKK Art. 5(2)(c) contract, (ç) legal obligation, (e) establishment of a right, (f) legitimate interest and, where required, Art. 5(1) explicit consent.
• Transfers: data may be transferred abroad to the service providers listed under "Third-Party Services" (including Google LLC and Apple Inc.) in line with KVKK Art. 9, and to competent public authorities under KVKK Art. 8 where legally required.
• Your rights: you can exercise your rights under KVKK Art. 11 by writing to info@varesma.com or via the contact form.

We may update this Policy to reflect changes to our Apps, the services we use or applicable law. The current version is always published at this address and the "Last Updated" date at the top of the page is changed. We will announce material changes through an in-app notice or store release notes and obtain your consent again where required.

For any questions or requests regarding this Policy or your personal data, please contact us: