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Privacy Policy — Thoughtline

Last updated: September 24, 2026

This privacy policy explains how the Thoughtline mobile app (the "App") collects, uses and protects your personal data. The App is developed by Tuğrul Yüksel ("we"), who is the data controller under the EU General Data Protection Regulation (GDPR) and the Turkish Personal Data Protection Law No. 6698 (KVKK).

The thoughts, emotions and notes you write in the App relate to your health, so they are special category personal data. That is why we encrypt free-text fields on your device before they are sent to our servers. We do not sell your data, use it for advertising, or share it with third parties.

1. Data We Collect

2. How Encryption Works

Free-text fields are encrypted on your device with AES-GCM. The encryption key is kept only in your device's Apple Keychain and is never sent to our servers, so we cannot read the encrypted text stored on the server either. Firebase's standard encryption in transit and at rest is applied on the server side as well.

3. Data That Stays on Your Device or Is Never Collected

4. Sharing With Your Therapist

"Share with my therapist" creates a PDF from the entries you choose, on your device. The PDF is not written to our servers; it is sent directly through the channel you pick in the iOS share sheet (e.g. email or messages). The PDF is unencrypted and subject to the recipient and the terms of the channel you use. Entries where the support screen was shown are excluded by default.

5. Sharing Your Mood With a Partner (optional)

If you choose to pair with a partner, they can see only the latest emotion you logged and its intensity. Your notes, thought records and activities are never shared, and entries where the support screen was shown are never shared with your partner. You can pause sharing or unpair at any time; your shared status is then deleted.

6. How We Use Data and Legal Bases

We use your data only to create your account, store and show your entries, sync them across your devices, carry out the sharing you choose, verify subscription access, fix crashes and (if you allow it) improve the App. We process health data on the basis of your explicit consent (GDPR Art. 9(2)(a); KVKK Art. 6), which you can withdraw at any time by deleting your account. Account and subscription data are processed to perform our contract with you, and crash reports on the basis of our legitimate interest in keeping the App working safely.

7. Third-Party Services and Data Location

Some of these providers process data outside your country. Transfers outside the European Economic Area rely on the providers' standard contractual clauses.

8. Retention and Deletion

Your data is kept for as long as your account is active. In the App, under Me → Delete my account and all my data, you can permanently delete your account together with all thought records, mood and activity entries, sharing history, partner pairing and the encryption key on your device. This cannot be undone. You can also request deletion by email.

9. Your Rights

You have the right to access your data, correct it, have it deleted, receive a copy in a portable format, restrict or object to its processing, and withdraw your consent at any time. If you are in the EU/EEA, you may also lodge a complaint with your local data protection authority. Send requests to the email address below; we respond within 30 days.

10. Medical Disclaimer

The App is a tool to help you practise cognitive behavioral therapy techniques on your own. It does not provide medical diagnosis or treatment, is not a substitute for a therapist and is not an emergency service. If you are in immediate danger, call your local emergency number. The App's "I need support right now" screen links to an independent directory of helplines in your country.

11. Age Requirement

The App is not designed for people under 18, and we do not knowingly collect data from this age group.

12. Changes

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

13. Contact

For questions and data protection requests: tugrulyukseel@gmail.com