Privacy Policy
WAY-LOO — LEGAL DOCUMENT SET (v1.0)
INFORMATIONAL TRANSLATION. The authoritative text of this set is the Turkish version (hukuki-set.tr.md). This English text is provided for information only; in case of any discrepancy the Turkish text prevails. (Same rule as the Distance Service Sales Agreement, Art. 13.3.)
STATUS: IN FORCE. v1.0 — 2026-08-25. Same procedure as the distance sales agreement: legal review is recommended; the bracketed fields have been filled in for publication. Contains two documents: (A) Terms of Use, (B) Privacy Policy and KVKK Disclosure Notice. Both are written to match the application's actual data behaviour — a description of the code, not marketing copy.
(B) PRIVACY POLICY and KVKK DISCLOSURE NOTICE
In force: v1.0 — 2026-08-25 · Data Controller: MRACLE Veri ve Bilgi Teknolojileri San. ve Tic. Ltd. Şti. (identity and contact details above) · KVKK requests: [email protected]
This text has been prepared under the disclosure obligation of Art. 10 of Law No. 6698 (KVKK) and describes the application's actual data behaviour.
1. What data we process
Driver side (anonymous):
- Device registration: platform, selected language, vehicle type, and for trucks optional dimensions/weight. Name, telephone and e-mail are not collected.
- Location: processed only while the application is open (in the foreground); used as an instantaneous query to show nearby listings and to build a route. Raw location history is not stored on the server and is not logged.
- Route: when you create a route, the origin/destination and the route geometry are processed in association with the anonymous device identifier. Journey progress is sent to the server not as raw coordinates but only as a coarse completion percentage.
- Impression events: which listing appeared on screen on which route is recorded anonymously and within the scope of the route.
- Search: your search queries are not recorded on the server; search history is kept only on your device (the last 10).
Road event reports: Road event reports (accident, roadworks, broken-down vehicle, hazard and — only in permitted countries — traffic control) are user statements; their accuracy is not guaranteed (Terms of Use §2.3 applies here as well). The location of the report is processed: the road point at the moment of reporting is recorded; raw location history is still not stored. Event and vote records are included in the 90-day deletion regime; afterwards only anonymous counts remain. The categories that can be reported may vary by country; a category that is closed in your country does not appear in the app at all.
Business side: telephone number, business name/location/category, listing content and imagery, agreement and consent records (version, date-time, IP), purchase records (number of days and the store transaction reference — your card/payment details never reach us, collection takes place at the store).
2. For what purposes and on what legal basis
Provision of the service and performance of the contract (KVKK Art. 5/2-c): device registration, routing, listing publication, purchase. Legal obligation (Art. 5/2-ç): consent and transaction records. Legitimate interest (Art. 5/2-f): security, abuse prevention, anonymous statistics. There is currently no processing activity requiring explicit consent; should one arise, your consent will be obtained separately.
3. An honest note about statistics
The figures presented to businesses (impressions, route passes, search matches) are aggregated from anonymous events along the listing axis. No business can see which device or person passed by, who they are, or any individual movement trace — the system is designed so as not to establish that link, and this is locked down by tests.
4. With whom data is shared
- Google Play / Apple App Store: collection of in-app purchases and receipt verification.
- Meta (WhatsApp Business): delivery of the business verification code over WhatsApp (telephone number and one-time code only).
- Maps, place search and route calculation run on our own servers; your location is not sent to third-party map services for these operations.
- The app does not collect crash or usage data; no third-party provider is used for this purpose.
- Competent authorities where legally required.
Transfer abroad: store and WhatsApp infrastructures may be located abroad; such transfer is an inherent part of the relevant service. (Lawyer's note: the KVKK Art. 9 transfer regime should be verified against current legislation.)
5. Retention periods
Raw event records (impressions, progress): 90 days, then deleted; only anonymous summaries remain. Journey sessions: closed 30 minutes after the progress signal stops. Consent/transaction records: for the statutory retention periods. When a business account is closed, the listing content is removed from publication and data not subject to statutory retention is deleted.
6. Your rights (KVKK Art. 11)
For your rights to access, rectify, erase, object to processing and your other rights under Art. 11, you may apply to [email protected]; applications are answered within the period set out in legislation. Because the driver side operates anonymously, matching records to an individual is in most cases not possible — this is the natural consequence of the data not being collected in the first place.
7. Children
The application is intended for adults who drive; it is not directed at persons under 18 and data is not knowingly collected from children.
8. Changes
The policy is versioned; material changes are announced within the application. The current version is always available at legal.way-loo.com.
The binding language of these texts is Turkish; versions in other languages are informational translations. In the event of any discrepancy between a translation and the Turkish text, the Turkish text prevails.