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PRIVACY POLICY AND PERSONAL DATA PROTECTION NOTICE

Last Updated: February 17, 2026  |  Effective Date: February 17, 2026  |  Version: 2.1

This Privacy Policy ("Policy") explains how punos ("Application", "App", "we", "us", "our") collects, uses, discloses, and safeguards your personal data when you use our mobile application and related services. This Policy applies to all users worldwide and addresses requirements under multiple data protection regulations.

Quick Summary: punos is a social audio platform that requires voice recordings and location data to function. We collect only what's necessary, protect your data with industry-standard security, never sell your personal information, and give you full control over your data.

1. DATA CONTROLLER AND CONTACT INFORMATION

Your personal data is processed by:

This Policy is issued in compliance with:

2. CATEGORIES OF PERSONAL DATA COLLECTED

2.1. Information You Provide Directly

Data Category Specific Data Purpose
Account Information Username, email address, password (hashed), birth year, gender (optional) Account creation and authentication
Profile Information Profile photo, bio, display name Public profile display
Communications Support requests, feedback, correspondence Customer support

2.2. Special Category / Sensitive Personal Data

⚠️ IMPORTANT NOTICE: The following data is classified as "special category" (GDPR) or "sensitive" (KVKK) personal data and requires your EXPLICIT CONSENT:

Data Type Description Legal Basis
Voice Data (Biometric) Voice recordings including: profile voice notes, voice messages, Snipps (short audio clips), location-based voice shares. Voiceprints may uniquely identify individuals. Explicit Consent (GDPR Art. 9(2)(a), KVKK Art. 6)
Precise Location Data GPS coordinates collected for the Voice Map feature. Includes foreground (app open) and background location (if permitted). Explicit Consent

2.3. Automatically Collected Data

2.4. Data from Third Parties

3. DEVICE PERMISSIONS

Our Application requests the following device permissions:

Permission Purpose Required?
Microphone Record voice notes, voice messages, and Snipps. Essential for core functionality. Yes (for voice features)
Location (Foreground) Show your voice content on the map, discover nearby content, enable "Nearby" feature. Yes (for map features)
Location (Background) Allow location-based notifications and continuous map updates when app is minimized. Optional
Camera Take profile photos directly within the app. Optional
Storage Save voice recordings locally, access photos for profile. Yes
Notifications Receive alerts for messages, likes, comments, and nearby activity. Optional

You can revoke any permission at any time through your device's Settings > Apps > punos > Permissions.

4. LEGAL BASIS FOR PROCESSING

Processing Activity Legal Basis (GDPR) Legal Basis (KVKK)
Voice recordings Explicit Consent (Art. 9(2)(a)) Explicit Consent (Art. 6)
Location tracking Explicit Consent (Art. 6(1)(a)) Explicit Consent (Art. 5(1))
Account management Contract Performance (Art. 6(1)(b)) Contract Performance (Art. 5(2)(c))
Analytics & improvement Legitimate Interest (Art. 6(1)(f)) Legitimate Interest (Art. 5(2)(f))
Advertising Consent / Legitimate Interest Consent / Legitimate Interest
Security & fraud prevention Legal Obligation (Art. 6(1)(c)) Legal Obligation (Art. 5(2)(a))

5. PURPOSES OF DATA PROCESSING

6. COOKIES AND TRACKING TECHNOLOGIES

7. DATA SHARING AND DISCLOSURE

We do NOT sell your personal data. We share data only as described below and never for monetary compensation.

7.1. Service Providers

Provider Service Data Shared Location
Google Firebase Cloud hosting, database, authentication Account data, content, usage logs USA/EU
Google AdMob Mobile advertising Advertising ID, device info USA
Google Analytics Usage analytics Anonymized usage data USA
Google Play Billing In-app purchases Purchase records USA

7.2. Legal Disclosures

We may disclose data when required by law, court order, or to protect rights and user safety.

Special Feature: "Mega Voice" and Extended Reach
When you use the "Mega Voice" feature, your voice recordings can be viewed, listened to, and marked on the map by users within a much wider geographical area (e.g., within a 2 km radius), including users who are not your friends. By using this feature, you explicitly acknowledge and agree to the disclosure of your location data and voice content to this broader audience.

7.3. Interaction Data (Likes and Ratings)

Your interactions on the platform (e.g., star ratings, likes given to voice recordings) are processed to determine content popularity, improve algorithmic recommendations, and analyze community trends. The ratings you provide may be displayed publicly as anonymized aggregated statistics (e.g., "Average Rating").

7.4. Business Transfers

In case of merger, acquisition, or asset sale, your data may be transferred with prior notice.

8. INTERNATIONAL DATA TRANSFERS

Your data may be transferred to countries outside your residence, including the United States. We ensure protection through:

9. DATA RETENTION

Data Type Retention Period
Account Information Duration of account + 30 days after deletion
Voice Content Until you delete it or delete your account
Location Data 90 days rolling (precise)
Usage Analytics 26 months (anonymized)
Financial Records 7 years (legal requirement)
Purchased Rights (Mega Voice etc.) Indefinitely until account deletion
Backup Systems Up to 90 days after deletion

10. DATA SECURITY

While we implement industry-standard security, no system is 100% secure. We cannot guarantee absolute security.

11. YOUR RIGHTS

11.1. Rights Under GDPR (EU/EEA Residents)

11.2. Rights Under KVKK (Turkey Residents)

11.3. Rights Under CCPA/CPRA (California Residents)

California Notice: We do NOT sell or share your personal information for cross-context behavioral advertising.

11.4. How to Exercise Your Rights

12. HOW TO WITHDRAW CONSENT

13. CHILDREN'S PRIVACY AND SAFETY

The Application is NOT intended for children under 13. We do not knowingly collect data from children. If discovered, such data will be deleted immediately. Contact support@punos.app if you believe a child has provided data.

For detailed information on our commitment to child safety and our zero-tolerance policies, please refer to our Child Safety Standards.

14. AUTOMATED DECISION-MAKING

We use automated systems for content moderation, spam prevention, and personalization. These do not produce legal effects. You can request human review by contacting us.

15. DATA BREACH NOTIFICATION

In case of a data breach posing risk to your rights, we will notify the relevant authority within 72 hours and inform you directly if there is high risk.

16. CHANGES TO THIS POLICY

We may update this Policy periodically. Material changes will be notified via in-app notification or email. Continued use after changes constitutes acceptance.

17. GOVERNING LAW

18. CONTACT US

Purpose Contact
General Support support@punos.app
Privacy Inquiries support@punos.app

19. CONSENT AND ACCEPTANCE

BY USING THIS APPLICATION, YOU ACKNOWLEDGE AND AGREE THAT:

  1. You have read and understood this Privacy Policy in its entirety.
  2. You provide EXPLICIT CONSENT for the processing of your Voice Data (Biometric) and Location Data as described herein.
  3. You understand that Voice Data is classified as special category/sensitive personal data.
  4. You acknowledge the international transfer of your data to countries including the United States.
  5. You can withdraw your consent at any time through the methods described in Section 12.
  6. You are at least 13 years of age.