Who is responsible for your information
The data controller for Turco is Barış Yalçınkaya, operating as a sole proprietor, with a postal address at Caferağa Mahallesi Şifa Sokak No: 19, Kadıköy / İstanbul / Türkiye.
Privacy contact: contact@learnturco.app. General contact: contact@learnturco.app.
Turco does not sell personal information, create advertising profiles, use advertising identifiers, or track you across other companies’ apps or websites. Limited first-party product analytics and crash diagnostics help us improve Turco and keep it reliable.
Information we handle
Learning data kept on your device
Your language choice, onboarding status, lesson progress, saved words, review history, and similar learning settings are stored in Turco’s local database on your device. Turco does not require a cloud learning account for the core experience.
Product analytics
Turco sends limited first-party usage events to Amplitude. These may include a randomly generated Amplitude installation identifier, onboarding step identifier and number, navigation direction or completion status, premium-access gate and paywall view or outcome, product identifier, app-home arrival, technical word-pack, category and dialogue identifiers, quiz type and completion stage, aggregate word, step and batch counts, My List actions and content type, target translation language, free or premium state, platform, app version, operating-system name and version, and event timestamp.
Turco configures Amplitude’s EU data centre and disables automatic capture, session replay, location collection, advertising identifiers, IDFV, carrier and regional enrichment, IP-address tracking, device language, device model, device manufacturer or brand, and Android API-level collection. We do not send your name, email address, precise location, learning answers, individual word identifiers, word, sentence or dialogue text, list names, private notes, saved content, content-sync telemetry, dictionary-filter changes, or feedback text to Amplitude.
Crash diagnostics
Turco uses Sentry to receive errors and crash reports. A report may contain the error type and sanitised error message, stack trace, event timestamp, app version, operating-system information, and Dart or Flutter runtime information needed to identify and fix the failure.
Turco does not set a Sentry user identity or send your name, email address, precise location, learning data, feedback text, HTTP request details, screenshots, view hierarchy, session replay, interaction history, performance traces, profiles, application logs, or analytics events to Sentry. Before a Dart event is sent, Turco removes user, request, breadcrumb, device, tag, custom context, and extra-data fields and redacts URLs, email addresses, and token-like values from diagnostic text. Native operating-system crash reports can contain low-level thread and device context required to diagnose the crash; Sentry project settings are configured to prevent storage of the sender’s IP address.
Purchases and subscription status
Apple or Google processes your payment. Turco and Adapty receive information needed to show the paywall and confirm entitlement, such as the store, product identifier, transaction and renewal status, price and currency, whether premium access is active, and when it expires. We do not receive your full payment-card details.
Feedback and support
If you report a content problem, we receive the content reference, issue type, optional message, app version, platform information, and a randomly generated installation identifier. Your email address is included only when you request a reply and choose to provide it.
A new-report notification sent to our support mailbox contains only limited report metadata, such as whether a reply was requested, the content and issue types, language, platform, and app version. It does not contain your email address, free-text message, content title, content identifier, or content snapshots. If you request a reply, an authorised operator reviews the report in our local Content Studio and may then use the address you provided to send a manual response through Zoho Mail. Turco does not send an automatic acknowledgement or automatic reply.
Website and security information
Vercel hosts and delivers learnturco.app. When you visit the website, Vercel may process request information such as IP address, browser or device type, requested URL, timestamps, and security or diagnostic logs to deliver and protect the website.
Cloudflare provides the related feedback infrastructure. When you submit feedback through the app, Cloudflare may process similar request information to deliver and protect that service.
Why we process information and our legal bases
Provide the app and remember local progress
Purpose: deliver lessons, audio, offline functionality, progress and settings. Legal basis: performance of our contract with you, Article 6(1)(b) GDPR. Device-local storage that is not transmitted remains under your control.
Deliver subscriptions and verify premium access
Purpose: show offers, process purchases and restores, prevent entitlement fraud, and provide paid features. Legal basis: performance of our contract, Article 6(1)(b); compliance with tax, accounting, refund, and consumer-law duties where applicable, Article 6(1)(c).
Measure, improve, and diagnose Turco
Purpose: understand onboarding drop-off, paywall reach, conversion, entry into the app, engagement with learning sessions and dialogues, and use of My List, and diagnose crashes and software errors so we can improve the experience and stability. Legal basis: our legitimate interests in improving and securing Turco, Article 6(1)(f) GDPR. We minimise the information collected and do not use it for advertising or cross-app tracking. You may object to this processing as described below.
Respond to feedback and support
Purpose: investigate content reports, fix errors, and reply when requested. Legal basis: performance of our contract where the request concerns the service, Article 6(1)(b), and our legitimate interest in maintaining accurate content and support, Article 6(1)(f). Where you voluntarily provide contact details for a reply, we use them only for that request.
Protect the service
Purpose: secure the app, website and feedback endpoint, prevent abuse, and diagnose failures. Legal basis: our legitimate interests in operating a safe and reliable service, Article 6(1)(f).
Meet legal obligations and establish legal claims
Purpose: comply with binding law and lawful requests, keep required business records, and establish, exercise or defend legal claims. Legal bases: Article 6(1)(c) and, for legal claims, Article 6(1)(f).
How analytics and crash diagnostics work
Amplitude is used only for Turco’s own product analytics, and Sentry is used only to diagnose software errors and crashes. Neither service is used for advertising, attribution, data brokerage, or tracking you across other companies’ apps or websites.
Turco does not connect the Amplitude installation identifier to a name, email address, advertising identifier, Apple ID, or user account. Adapty’s external analytics forwarding remains disabled, so subscription events are not linked to the Amplitude identifier through Adapty.
You may object to processing based on legitimate interests by contacting us at the privacy address below. We will assess and honour the request where required by applicable law.
Service providers and recipients
- Amplitude provides first-party product analytics using its EU data centre. It receives only the limited events described above.
- Adapty delivers the paywall and verifies premium entitlement. Its external analytics forwarding, advertising identifier collection, and IP-address collection are disabled in Turco’s SDK configuration.
- Sentry provides error and crash diagnostics. Turco uses Sentry’s EU data-storage region and the data-minimising configuration described above.
- Vercel hosts and delivers learnturco.app and provides website content delivery and security infrastructure.
- Cloudflare provides the related feedback infrastructure, including feedback storage and transactional notification delivery, and protects these services from abuse.
- Zoho Mail provides our business support mailbox. When you request a reply or contact us by email, Zoho may process the recipient address and the resulting support correspondence. Our Zoho Mail service uses Zoho’s European Union data centre.
- Apple App Store and Google Play process payments, billing, refunds, and store subscription management under their own privacy terms.
- Professional advisers and authorities may receive information where reasonably necessary for legal compliance, audits, claims, or protection of rights.
We require processors acting on our behalf to use information only under our instructions, keep it secure, and comply with applicable data-protection law.
Transfers outside the EEA, UK, or Switzerland
Amplitude’s product-analytics data is directed to its EU data centre, Sentry diagnostic data is directed to Sentry’s EU data-storage region in Germany, and our Zoho Mail account uses Zoho’s EU data centre. Amplitude, Adapty, Sentry, Vercel, Cloudflare, Zoho, their support teams, or their subprocessors may nevertheless process information from countries outside your country, including outside the European Economic Area, the United Kingdom, or Switzerland.
Where a transfer is not covered by an adequacy decision, we rely on appropriate safeguards such as the European Commission’s Standard Contractual Clauses, the UK International Data Transfer Addendum or equivalent contractual safeguards, together with supplementary technical and organisational measures where required. Where applicable, a provider may also rely on a recognised adequacy framework such as the EU–US Data Privacy Framework.
You may contact us for more information about the safeguard relevant to a particular transfer, subject to necessary confidentiality protections.
How long we keep information
Learning progress and settings are stored locally on your device. You can remove this local data by clearing Turco’s app data. Removing local data does not delete records already sent to our service providers or cancel a store subscription.
Product analytics and crash reports are subject to the retention settings and policies of Amplitude and Sentry. Subscription and entitlement records are subject to Adapty’s and the relevant app store’s retention settings and policies. These periods can vary by provider, data type, and service configuration.
Feedback and support records are used to investigate reports and respond to requests. Website and feedback-service logs are used for delivery, security, and diagnostics. Retention depends on the service configuration, the purpose of the record, and applicable legal requirements.
Records may need to be retained to meet legal obligations, resolve billing or support issues, prevent fraud, or establish, exercise, or defend legal claims.
Your choices and data-protection rights
Depending on where you live and subject to legal conditions and exceptions, you may have the right to:
- request access to and a copy of your personal information;
- correct inaccurate or incomplete information;
- request deletion of information;
- restrict how information is processed;
- receive information you provided in a structured, commonly used, machine-readable format and transmit it to another controller;
- object to processing based on legitimate interests;
- complain to the data-protection supervisory authority where you live, work, or believe an infringement occurred.
Turco does not offer registration or a user login account. Analytics, diagnostics, and subscription services may nevertheless hold records associated with technical identifiers. An email address alone may not identify those records; additional information may be needed to locate them. Your rights remain subject to applicable law.
Turco does not use personal information for solely automated decisions that produce legal or similarly significant effects. We may ask for reasonable information to verify and locate a request. You are not required to use a particular form, and exercising your rights will not result in discrimination.
Security, children, and policy changes
We use technical and organisational safeguards appropriate to the information and risk, including data minimisation, restricted provider access, encrypted transport, local storage for learning progress, and disabled advertising identifiers. No system can guarantee absolute security.
Turco is not directed to children under 13. Where local law requires a higher age to consent to data processing, a parent or legal guardian must provide any required authorisation. If you believe a child provided personal information improperly, contact us.
We may update this policy as Turco, our providers, or applicable law changes. The latest version and effective date will appear here. We will provide appropriate notice of material changes where required.
Contact us or exercise a right
Controller: Barış Yalçınkaya (sole proprietor)
Address: Caferağa Mahallesi Şifa Sokak No: 19, Kadıköy / İstanbul / Türkiye
Privacy email: contact@learnturco.app
Please describe your request and include any feedback receipt that may help locate the relevant record. You may also contact your competent supervisory authority directly.