Lulu Privacy Policy

 

Lulu Privacy Policy

Last updated: October 21, 2026

This policy explains what personal data is collected when you use the Lulu mobile application (the “App”), how it is used, and your rights. The App is developed by Clappy LLC (“we”), who is the data controller. Data is processed in accordance with the Turkish Personal Data Protection Law No. 6698 (KVKK) and, where applicable, the EU General Data Protection Regulation (GDPR).

1. Data we collect

  • Account data: email address and password (stored only in hashed form). If you sign in with Google, the name, email address and profile photo shared by Google.
  • Profile data: your name and optional profile photo.
  • Business data (providers): business name, category, description, address, map location, photos, working hours, services and prices, staff details. This information is shown publicly in the App.
  • Bookings: booking date and time, selected service, status, and notes added by you or the business.
  • Messages: messages you exchange between customers and businesses, stored only so they can be delivered and displayed.
  • Favorites and reviews: businesses you favorite; reviews and ratings you write (reviews are public together with your name).
  • Location: if you grant permission, your device’s precise or approximate location is used to show nearby businesses. It is sent to our server during a search but is not stored with your account. You can revoke the permission at any time in your device settings.
  • Notification token: your device’s push notification token, used to send booking and message notifications.
  • Subscription data (providers): whether your subscription is active and when it expires. Payments are processed by Google Play or the App Store; we never see or store your card details.

2. How we use data

  • To create your account, sign you in and verify your email address,
  • To list, search and show businesses on a map,
  • To create and manage bookings and notify the parties involved,
  • To enable messaging between customers and businesses and send notifications,
  • To verify subscriptions and manage access to business features,
  • To keep the service secure, prevent abuse and comply with legal obligations.

We do not sell your data or use it for advertising, and the App contains no third-party advertising or analytics SDKs.

3. Legal bases

We process your data on the basis of performing our contract with you (providing the App), our legitimate interests (security and service improvement), legal obligations and, where required, your consent (e.g. location and notification permissions).

4. Who we share data with

Data is shared only with the following service providers, and only as needed to run the service:

  • Supabase – database, authentication and file storage,
  • Google – Google Sign-In, Firebase Cloud Messaging (notifications) and Google Maps,
  • Adapty – subscription status management,
  • Google Play / Apple App Store – subscription payments.

A business you book with or message can see your name, profile photo, booking details and messages. We may also disclose data to authorities when legally required.

These providers may operate servers outside Türkiye (e.g. in the EU or US), so your data may be transferred abroad. Such transfers are made with the safeguards required by KVKK and GDPR.

5. Retention

We keep your data for as long as your account is active. When you delete your account, your profile, business, bookings, messages, favorites, reviews and notification tokens are permanently deleted. Records we are legally required to keep are retained only for the required period.

6. Deleting your account and data

You can permanently delete your account and all associated data in the App via Profile → Delete account. If you cannot access the App, email info@clappystudio.com from your registered address to request deletion. If you have an active subscription, you must also cancel it in Google Play or the App Store.

7. Your rights

Under KVKK Article 11 and the GDPR you have the right to access, rectify or erase your data, object to or restrict processing, data portability, and to withdraw consent. Send requests to the contact address below; we respond within 30 days. You may also lodge a complaint with the Turkish Personal Data Protection Authority or your local data protection authority.

8. Security

Data is encrypted in transit (HTTPS) and access is limited to authorized users through row-level security rules. No system is completely secure, but we take reasonable technical and organizational measures to protect your data.

9. Children

The App is not intended for children under 13, and we do not knowingly collect data from them. If we learn that we have, we will delete it.

10. Changes

We may update this policy from time to time. The current version is always published on this page, and we will notify you in the App of significant changes.

11. Contact

Clappy LLC
Email: info@clappystudio.com

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