Privacy Policy
This Privacy Policy explains how Luzzi processes your personal data. It is prepared under Turkish Personal Data Protection Law No. 6698 (KVKK) and, for users in the European Economic Area and the United Kingdom, the General Data Protection Regulation (GDPR).
1. DATA CONTROLLER
Controller: Emre Uysal
Location: Ankara, Türkiye
Email: privacy@luzziapp.com
A full postal address is provided on request via the email address above.
2. PERSONAL DATA WE PROCESS
- Identity and contact: name, username, email, phone, gender, (optional) date of birth, profile photo.
- Content: outfit photos and (optional, muted) outfit videos you share, product tags (type, brand, price, link), captions, comments and messages.
- Body information (optional): height and weight. Only if you enter them and turn on "Show on my outfits" are they shown to everyone in your outfit captions, based on your explicit consent. You can turn this off, remove it from your outfits or delete the values at any time in Settings > Height & Weight.
- Usage data: ratings, favorites, follow relationships, view counts and in-app interactions.
- Technical data: device and app version, crash logs.
- Ad measurement data: app install and open events, a random app-specific device identifier, device model, iOS version, language, time zone and IP address (Meta SDK; see Section 10).
- Notification token: used to deliver notifications to your device through Apple Push Notification service (APNs) and Firebase Cloud Messaging. You can turn off notification types in Settings; a type you turn off is never sent. The token is deleted when you sign out.
- Location (optional): when you search for stores, and only if you allow it, your device location is read once while the app is open to show the distance to nearby stores. This location stays on your device; it is not sent to or stored on our servers. It is passed to Apple Maps during the search to find nearby results. If you don't allow it, distances are not shown and the rest of the app works the same.
- Approximate region: a city-level estimate is made from the network your connection comes from; your device location is not used for this. It is used in aggregate to understand where to improve the service.
- Last active time: to see whether an account is active.
3. PURPOSES AND LEGAL BASES
- Creating and managing your account — performance of a contract (KVKK Art. 5/2-c; GDPR Art. 6(1)(b)).
- Showing content and running the feed, trends and explore rankings — performance of a contract (KVKK Art. 5/2-c; GDPR Art. 6(1)(b)).
- Enforcing community guidelines, reviewing reports and abuse — legitimate interest and legal obligation (KVKK Art. 5/2-f and 5/2-ç; GDPR Art. 6(1)(f) and 6(1)(c)).
- Security, debugging and service continuity — legitimate interest (KVKK Art. 5/2-f; GDPR Art. 6(1)(f)).
- Showing your height and weight on your outfits — explicit consent (KVKK Art. 6; GDPR Art. 9(2)(a)). Because body information can relate to health, it is processed only if you enter it and turn on "Show on my outfits". You can withdraw consent at any time in Settings > Height & Weight and delete the values. Withdrawing consent does not affect the lawfulness of processing before the withdrawal.
- Measuring how many installs and how much use our ads bring — legitimate interest (KVKK Art. 5/2-f; GDPR Art. 6(1)(f)). Details in Section 10.
Luzzi does not send marketing messages, so no consent is collected for that purpose.
4. RETENTION
- Account and content data: for as long as your account is open.
- Messages: stored on our servers for as long as your account is open and are not end-to-end encrypted. They may be read by authorized people when reviewing reports, detecting abuse or meeting legal obligations. Message data may be evaluated in aggregate and statistically to improve the service; this does not aim to read individual conversations. Messages are not used for advertising and are not shared with third parties.
- When you delete your account: your content and profile data are deleted immediately and removed from technical backups within 30 days.
- Report and moderation records: for the applicable limitation periods (at most 10 years).
- Records that the law requires us to keep are kept for the required period.
5. INTERNATIONAL TRANSFERS
The service runs on Firebase, provided by Google LLC (authentication, database, file storage, notifications and crash logs); the database and server functions are located in the European Union. Notifications are delivered through Apple Inc.'s push service (APNs); the website, photo delivery, outfit video storage and the city-level region estimate are served by Cloudflare, Inc.; ad measurement events are sent to Meta Platforms Ireland Limited. Your personal data may therefore be processed outside your country, including in Turkey and the United States. Such transfers rely on KVKK Art. 9 and, for the EEA/UK, on the European Commission's Standard Contractual Clauses and, where applicable, the EU-U.S. Data Privacy Framework, together with the security measures the providers commit to.
6. SHARING
- Other users: the outfits you share (with your height and weight if you turned this on), your profile information and comments can be seen by other users, depending on your privacy setting.
- Service providers: the infrastructure and notification services listed above.
- Meta: app install and open events and device information, to measure our ads (see Section 10).
- Authorities: where required by law.
We do not sell your personal data.
7. CHILDREN
Luzzi is not designed for people under 13 (or the higher minimum age required in your country) and we do not knowingly collect data from them. If we learn that an account belongs to a user under this age, the account is closed and the data is deleted.
8. YOUR RIGHTS
Depending on where you live, you have the right to: know whether your data is processed and access it; request information about the purposes of processing and the recipients; correct inaccurate or incomplete data; delete your data; restrict processing; receive your data in a portable format; object to processing based on legitimate interest; object to decisions made solely by automated means that affect you; withdraw consent at any time; and seek compensation for damages. If you are in the EEA or the UK, you can also lodge a complaint with your local data protection authority.
Send your requests to privacy@luzziapp.com; we respond within 30 days at the latest. You can also use two tools in the app:
- Settings > Download My Data — gives you a readable copy of your data.
- Settings > Delete Account — permanently deletes your account and content.
9. SECURITY
Your data is encrypted in transit and protected by access controls. No system is perfectly secure, so we recommend using a strong password for your account.
10. ANALYTICS
To measure how many installs and how much use our Instagram and Facebook ads bring, the app includes the Meta SDK. When the app is installed and each time it opens, the following is sent automatically to Meta Platforms Ireland Limited: the event type (install, app open, session length), a random app-specific device identifier, device model, iOS version, language, time zone and IP address. Your name, username, email, phone number, photos, outfits and messages are not sent. The app does not ask for Apple's tracking permission (ATT) and does not collect the advertising identifier (IDFA); we do not track you across other apps and websites. Meta processes this data under its own privacy policy.
Usage statistics are reviewed only if you gave consent, only to improve the product, and without linking them to your identity.
11. CHANGES
We may update this policy. We will let you know in the app about significant changes; the current version is always published at https://luzziapp.com/en/privacy.
Contact: privacy@luzziapp.com