Privacy Policy

1. Who we are

Laterland (the “App”) and the website at cglrsert.github.io/laterland (the “Website”) are developed and published by Çağlar Sert, an independent developer established in the Republic of Türkiye (“we”, “us”, “our”).

For the limited personal data described in this policy, we are the controller within the meaning of the EU General Data Protection Regulation 2016/679 (“GDPR”) and the UK GDPR, and the data controller (veri sorumlusu) within the meaning of the Turkish Personal Data Protection Law No. 6698 (“KVKK”).

Contact for all privacy matters: caglar.sert1@gmail.com.

2. Scope of this policy

This policy applies to:

• the Laterland iOS app, including its Share Extension;
• this Website;
• communication with us, such as support emails;
• our TestFlight beta program, if you take part in it.

It does not apply to services operated by others that you may use together with Laterland, such as Apple's App Store, iCloud, Photos, Calendar, or websites you save and open. Their own privacy policies apply.

3. The App collects no personal data

“Collect” means transmitting data off your device in a way that allows us or a third party to access it. The App does not do this. In particular:

• There is no account, sign-up or login.
• We operate no servers that receive data from the App.
• The App contains no analytics, advertising, attribution, crash-reporting or other third-party SDKs.
• The App does not track you across apps or websites owned by others, and does not use the advertising identifier (IDFA).
• The App does not use your location, contacts, health data, microphone or browsing history.

This is why the App Store privacy label for Laterland reads “Data Not Collected”.

4. Information that stays on your device

To work, the App stores the following information locally on your iPhone, inside the App's private storage (and a shared container used only by the App and its own Share Extension). We have no access to it.

Because this information never reaches us, we cannot view, export, correct or delete it for you, and we cannot recover it if it is lost. You stay in full control (see Your rights and choices).

5. How screenshots are read

When you import screenshots, the App uses Apple's on-device frameworks (such as Vision for text recognition and Natural Language for language detection) to find titles, links, places and durations and to suggest a purpose. This processing happens entirely on your iPhone. No image or text is sent to us or to any cloud service.

These suggestions are conveniences only. They have no legal or similarly significant effect on you, and you can change or ignore every suggestion. Laterland does not carry out automated decision-making or profiling within the meaning of Article 22 GDPR.

6. Permissions the App asks for

You can change these permissions at any time in the iPhone Settings app. Declining a permission only disables the related feature.

7. Network connections made by the App

The App has no backend. It connects to the internet only in these situations, which you control:

• Link previews. When you save a web link and link previews are on, your iPhone asks that website directly for its title and preview image, using Apple's LinkPresentation framework. That website receives the technical information any browser visit sends (such as your IP address and device type) and is responsible for it under its own privacy policy. We receive nothing. You can turn link previews off in Settings → Link previews.
• Opening links. When you open a saved link, it opens in Safari's in-app view. Your visit is between you and that website.

8. Services provided by Apple

Some services around the App are provided by Apple Inc. and its affiliates (“Apple”) as an independent controller under Apple's own privacy policy (apple.com/legal/privacy):

• App Store purchase and download. Apple processes your payment and Apple ID. We receive only aggregated sales and download reports that do not identify you.
• App Analytics and crash reports. If you have chosen in iOS to share analytics with app developers, Apple may provide us with aggregated usage statistics and anonymized crash reports. These do not identify you, and we use them only to fix bugs and improve stability.
• iCloud and device backups. Depending on your iPhone settings, iOS may include the App's data in your iCloud or computer backup. That backup is managed by you and Apple, not by us.
• TestFlight. See Beta testing.

9. Backup files you create

The App lets you create a backup file (Settings → Back up now) and save it wherever you choose, such as Files, iCloud Drive or another device. The file contains your saves, screenshots, memories, photos, progress and settings. We never receive or upload it. Backup files are checked for integrity but are not encrypted by the App, so please store them somewhere private. Sharing a backup file with someone else is your decision.

10. When you contact us

If you email us at caglar.sert1@gmail.com or otherwise contact us, we process:

• your email address and name (as shown by your email provider);
• the content of your message and anything you attach (for example screenshots, device model, iOS and App version);
• our correspondence with you.

Purpose: to answer your question, solve your problem, fix bugs and keep a record of the request.
Legal basis: taking steps at your request and performing our contract with you (Art. 6(1)(b) GDPR; Art. 5(2)(c) KVKK), and our legitimate interest in providing good support and improving the App (Art. 6(1)(f) GDPR; Art. 5(2)(f) KVKK).
Retention: for as long as needed to handle your request and up to 24 months afterwards, unless a longer period is required to establish, exercise or defend legal claims, after which it is deleted.
Service provider: our email is provided by Google (Gmail). Your message is therefore stored on Google's infrastructure, which may be located outside your country. Please do not send us sensitive information (such as health data) that we do not need.

11. Beta testing (TestFlight)

If you join the Laterland beta through Apple's TestFlight, Apple shares with us the name and email address used for your invitation, your tester status, and any feedback, screenshots and crash reports you choose to send through TestFlight.

Purpose: to run the beta, invite you to builds and improve the App.
Legal basis: performing our agreement with you to test the App (Art. 6(1)(b) GDPR; Art. 5(2)(c) KVKK) and our legitimate interest in improving the App (Art. 6(1)(f) GDPR; Art. 5(2)(f) KVKK).
Retention: while you are a tester and up to 12 months after the beta ends or you leave it. You can leave at any time in the TestFlight app or by asking us to remove you.

12. This Website

The Website is a static site hosted on GitHub Pages (GitHub, Inc.). When you visit it, GitHub's servers necessarily process technical data such as your IP address, browser type and the requested page, including in server logs used for security and abuse prevention. GitHub acts under its own privacy statement (GitHub Privacy Statement). We do not receive these logs.

• The Website uses no cookies, no analytics, no advertising and no social-media plugins.
• Fonts, images and scripts are served from the Website itself; no requests are made to third-party font or script providers.
• When you change the language, the Website remembers your choice for the current browser tab only, using your browser's session storage. It is deleted when you close the tab and is never sent to us.

13. Sharing and selling

We do not sell personal information and do not share it for cross-context behavioral advertising, as those terms are defined in the California Consumer Privacy Act as amended by the CPRA (“CCPA”). We do not rent, trade or otherwise disclose personal data to third parties, except:

• to the service providers named in this policy (Google for email, GitHub for hosting), only as needed to provide those services;
• where we are required to do so by law, court order or a competent authority, or where necessary to establish, exercise or defend legal claims.

14. International transfers

The App keeps your content on your device, so it is not transferred anywhere by us. The limited personal data described under When you contact us, Beta testing and This Website may be processed by Google, Apple and GitHub in countries outside Türkiye, the European Economic Area or the United Kingdom, including the United States.

Where the GDPR or UK GDPR applies, such transfers rely on an adequacy decision (such as the EU–U.S. Data Privacy Framework, where the recipient is certified) or on the providers' Standard Contractual Clauses. Where the KVKK applies, transfers abroad are carried out in accordance with Article 9 of the KVKK, in particular where the transfer is necessary to answer your request or to perform our agreement with you.

15. How long we keep data

When a retention period ends, we delete the data or make it anonymous, in line with the KVKK Regulation on the Erasure, Destruction or Anonymization of Personal Data.

16. Security

Data on your iPhone is protected by iOS security features, including Data Protection encryption tied to your device passcode. We recommend that you use a passcode and keep iOS up to date. For the limited data we handle (emails and beta feedback), we use accounts protected by strong passwords and two-factor authentication and limit access to ourselves. No method of transmission or storage is perfectly secure, but we take reasonable technical and organizational measures appropriate to the risk.

17. Your rights and choices

Control in the App

• Edit or delete any save, memory or photo directly in the App.
• Delete everything with Settings → Erase all data, or by deleting the App.
• Export everything with Settings → Back up now.
• Turn off link previews, notifications, camera or calendar access at any time.

Rights under the GDPR and UK GDPR

If you are in the EEA or the UK, you have the right to access your personal data, to rectification, to erasure, to restriction of processing, to data portability, to object to processing based on legitimate interests, and to withdraw consent where processing is based on consent. You also have the right to lodge a complaint with your local data protection authority (in the UK, the Information Commissioner's Office).

Rights under the KVKK (Article 11)

If the KVKK applies to you, you have the right to: learn whether your personal data is processed; request information about it; learn the purpose of processing and whether data is used for that purpose; know the third parties in Türkiye or abroad to whom data is transferred; request correction of incomplete or inaccurate data; request erasure or destruction under Article 7; request that third parties to whom data was transferred be notified of such correction or erasure; object to a result against you arising exclusively from automated analysis; and claim compensation for damage caused by unlawful processing.

You may submit your request in writing, or by email from the address you have previously given us, to caglar.sert1@gmail.com, in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller. We will respond free of charge within 30 days at the latest. If your request is refused or you are not satisfied with our answer, you may complain to the Personal Data Protection Board (kvkk.gov.tr).

Rights under U.S. state privacy laws (including the CCPA)

Residents of California and other U.S. states with comprehensive privacy laws may have the right to know and access the personal information we hold about them, to correct it, to delete it, to opt out of its sale or sharing, and not to be discriminated against for exercising these rights. We do not sell or share personal information and do not use sensitive personal information for purposes that require a right to limit. In the past 12 months, the only categories of personal information we have received are identifiers and the content of communications (such as your email address and messages, when you contacted us), for the business purposes described in When you contact us. To exercise a right, email us; you may also use an authorized agent. We will verify your request using the email address you contacted us from.

Because App content never leaves your device, we usually cannot find any data about you except emails you have sent us. Requests about App content are best handled directly in the App, as described above.

18. Children

Laterland is rated 4+ and is suitable for a general audience. It does not collect personal information from anyone, including children under 13 (or the equivalent minimum age in your country). We do not knowingly receive personal information from children through support or TestFlight. If you believe a child has sent us personal information, contact us and we will delete it. This is consistent with the U.S. Children's Online Privacy Protection Act (COPPA).

19. Changes to this policy

We may update this policy, for example when we add features or when the law changes. We will change the “Last updated” date at the top and keep the version number. If a change materially affects how personal data is handled, for example if the App would ever start collecting data, we will tell you in advance in the App's release notes and on this page, and, where required, ask for your consent first.

20. Contact and complaints

Çağlar Sert, Laterland, Republic of Türkiye
Email: caglar.sert1@gmail.com

You can also contact a supervisory authority: in Türkiye, the Personal Data Protection Authority (Kişisel Verileri Koruma Kurumu, kvkk.gov.tr); in the EU, the data protection authority of your country of residence (list of EU authorities); in the UK, the ICO (ico.org.uk).

This policy is available in English and Turkish. For users in Türkiye, the Turkish version prevails in case of any inconsistency; otherwise the English version prevails.