LOLOPrivacy Policy
1. Scope
This policy explains how personal data is processed through the LOLO mobile app and related services (“LOLO”, “we”). It is prepared under Turkish Personal Data Protection Law No. 6698 (KVKK) and, where applicable, the GDPR.
2. Data we collect
- Account data: name and email shared by Apple or Google at sign-in (a relay address if you use Apple’s “Hide My Email”), provider user ID.
- Profile data: username, display name, profile/cover photo, bio; optional gender, age and city; the frequencies you choose.
- Content: posts, photos, comments, signals, Daily Spark answers, direct messages. The text and images of posts and comments are sent to the OpenAI moderation service for automated review before publication (for moderation only).
- Interactions: follows, blocks, reports, notifications.
- Transaction data: token balance and history, subscription status; purchase verification data provided by Apple and RevenueCat (product, amount, currency, transaction ID — we never see card details).
- Technical data: IP address, device model, iOS and app version, language/time zone, push token, last-seen time, error logs.
- Ad measurement data: in-app events (registration, content views, search, posting, sending messages, purchases/subscriptions), the Meta SDK install ID and — only if you allow it — your device’s advertising identifier (IDFA). See “Ad measurement and tracking”.
3. How we use it
- Create your account and manage your session
- Personalize the feed, discovery and people suggestions (frequencies, optional profile details)
- Deliver messages and notifications
- Verify token purchases and manage your balance
- Measure the effectiveness of LOLO’s own ad campaigns (Meta)
- Security, fraud and abuse prevention; reviewing reports and enforcing community rules
- Complying with legal obligations
4. Sharing
We do not sell your personal data. Data is shared only as needed to run the service with: Hetzner Online GmbH (hosting, EU), Google Firebase (authentication, push delivery), OpenAI (automated content moderation), Apple (Sign in with Apple, in-app purchases), RevenueCat Inc. (purchase and subscription validation/management, as a processor), Meta Platforms (ad measurement — see below). We may disclose data to authorities where legally required.
5. Ad measurement (Meta) and tracking permission
We advertise LOLO on Facebook/Instagram. To measure how many people our ads bring to the app, we use the Meta SDK and the Meta Conversions API. The following is sent to Meta: the event type (e.g. registration, purchase, message sent — the content of messages, posts or comments is never sent), purchase amount and currency, your SHA-256-hashed email address and hashed user ID, hashed gender and city if provided, IP address, device/app information and the Meta SDK install ID.
On iPhone, after you start using the app, it asks for permission through Apple’s App Tracking Transparency (ATT) prompt. If you choose “Ask App Not to Track”, your advertising identifier (IDFA) is never read or shared; events sent to Meta are flagged as “tracking not allowed” and Meta may use them only for the aggregated measurement Apple permits. You can change your choice any time in Settings › Privacy & Security › Tracking. How Meta processes data: Meta Privacy Policy.
6. Public information
Your username, display name, profile photo, bio, frequencies and posts are visible to other users. Direct messages are visible only to the participants; reported messages may be reviewed by our moderation team.
7. Retention and deletion
We keep your data while your account is active. Delete your account at any time in the app via Profile → Settings → Delete account: your profile details, email, follow relationships, device and ad-measurement records (including any advertising ID) are deleted and your posts and comments are taken down. Purchase and token records may be retained in anonymized form for legally required periods.
8. Your rights
Under KVKK Art. 11 and the GDPR you may access, rectify, erase, restrict, object to processing and port your data. Contact: [email protected].
9. Age requirement
LOLO is only for users 18 and over. We close accounts we determine belong to minors.
10. Security
Data is transmitted over encrypted connections (HTTPS/TLS) and access is restricted by authorization. No system is 100% secure, but we apply reasonable technical and organizational measures.
11. Changes and contact
We may update this policy and will announce material changes in the app. Questions: [email protected].